- 13 - lease office space and equipment from petitioner. Petitioner reported gross receipts in the amount of $266,072 for 1995. This is an increase from petitioner’s reported gross receipts in the amount of $94,000 for 1994. Petitioner failed to reconcile its increase in gross receipts with its claim to have suffered devastating adverse impacts from Kaufman’s suspension. As evidence of petitioner’s abandonment of tangible assets, petitioner provided a document entitled “JHK Enterprises Equipment Schedule as of 12/1/96” (the equipment schedule). The equipment schedule is a list of tangible assets. Some of the assets are listed as “In Service”, others as “Abandoned”, and still others as “1/2 Abandoned 1/2 In Service”. The equipment schedule does not list a date of abandonment or a method of abandonment for any asset. The equipment schedule does not reflect that petitioner abandoned any tangible asset during 1995. At most, it reflects that petitioner abandoned some tangible assets before December 1, 1996. Petitioner has not established that it abandoned any tangible asset in 1995. Aside from self-serving testimony of petitioner’s president, petitioner has not provided any evidence that it abandoned tangible assets during 1995. Assuming, for the sake of argument, that petitioner abandoned tangible assets during 1995, petitioner’s loss deduction would be limited to its adjusted basis in the abandonedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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